United States Government Accountability Office
Report to Congressional Committees
December 2015
OPERATIONAL
CONTRACT
SUPPORT
Additional Actions
Needed to Manage,
Account for, and Vet
Defense Contractors
in Africa
GAO-16-105
December 2015
OPERATIONAL CONTRACT SUPPORT
Additional Actions Needed to Manage, Account for,
and Vet Defense Contractors in Africa
Highlights of GAO-16-105, a report to
congressional committees
Why GAO Did This Study
What GAO Found
Since its establishment in 2008,
AFRICOM has increased its footprint in
Africa to support its mission—building
African partner capabilities and
deterring threats to regional security. In
tandem with AFRICOM’s growing
footprint will be a continued reliance on
contractors to support the command’s
operations. Accordingly, AFRICOM
and subordinate commands must be
able to plan for and integrate OCS
during operations. House Report 113446 included a provision for GAO to
review OCS in Africa.
U.S. Africa Command (AFRICOM) has established a formal operational contract
support (OCS) organizational structure at its headquarters to serve as the central
coordination point to manage, plan for, and assess OCS. However, except for
U.S. Army Africa, AFRICOM’s subordinate commands do not have OCS
organizational structures with dedicated personnel to manage OCS. Officials
from AFRICOM’s subordinate commands stated that applying OCS concepts
would be helpful to avoid duplication of work and increased costs. One structure
that the Department of Defense (DOD) has introduced is an OCS Integration
Cell, an entity with dedicated personnel to provide staff integration and promote
coordination on OCS issues; such a cell could help identify and address gaps at
AFRICOM’s commands, especially in a joint environment like Combined Joint
Task Force-Horn of Africa, where contracting officials stated that some military
tenants have arrived without informing responsible officials about the number of
contractors accompanying them. AFRICOM has also developed a scorecard to
assess OCS management capabilities at the subordinate commands against
certain standards, but these assessments have not always been accurate
because the standards have not been clearly defined or consistently applied.
Without clearly defined assessment standards, AFRICOM cannot accurately
assess the OCS actions taken by subordinate commands.
This report examines the extent to
which AFRICOM (1) has an
organizational structure in place to
manage, plan for, and assess OCS; (2)
accounts for contractor personnel; and
(3) vets non-U.S. contractors and
contractor employees. To conduct this
work, GAO evaluated AFRICOM’s
OCS organizational structures and
conducted site visits to Djibouti, Niger,
and Uganda to collect information on
accountability and vetting processes.
GAO selected these locations based
on the types of contractor employees
represented, among other factors.
What GAO Recommends
GAO made recommendations to DOD
regarding types of contractor personnel
to account for, foreign vendor vetting
process development, and guidance
for contractor accountability and
employee screening, among others.
DOD generally concurred, but did not
concur that AFRICOM should develop
contractor accountability guidance
because it was in the process of doing
so. GAO continues to believe the
recommendations are valid, as
discussed in this report.
View GAO-16-105. For more information,
contact Cary Russell at (202) 512-5431 or
russellc@gao.gov.
AFRICOM does not have a complete picture of the number of contractor
personnel supporting its operations in the region. AFRICOM uses two primary
sources—daily personnel status reports and the Synchronized Predeployment
and Operational Tracker, a DOD contractor personnel accountability database—
to collect contractor personnel accountability information, but neither source
provides comprehensive accountability or visibility of DOD contractor personnel
on the continent because the total number of local national contractor personnel
are not being included in either, and the numbers of U.S. citizen and third country
national contractor personnel vary between the two. Without clear guidance on
how to comprehensively account for contractor personnel, it will be difficult for
AFRICOM to ensure that it has full visibility over who is supporting its operations.
AFRICOM conducts some limited vetting of potential non-U.S. contractors, also
referred to as vendors, but it has not established a foreign vendor vetting process
or cell that would preemptively identify vendors who support terrorist or other
prohibited organizations. AFRICOM has not yet established a foreign vendor
vetting cell because while DOD guidance discusses the benefit of a cell, it does
not require it or specify under what conditions it would be appropriate.
Additionally, DOD sites in Africa use background investigations to determine the
trustworthiness of contractor employees with access to DOD facilities. However,
not all AFRICOM sites are incorporating additional screening measures, such as
biometric screening or counterintelligence interviews, based on the specific risks
at each site. As a result, AFRICOM is at risk of not exercising the appropriate
level of vendor vetting or contractor employee screening on the African continent
to protect DOD personnel from insider threats.
United States Government Accountability Office
Contents
Letter
1
Background
AFRICOM Has Established an Organizational Structure to
Manage, Plan for, and Assess OCS, but Some Subordinate
Commands Have Not Done So
AFRICOM Cannot Comprehensively Account for DOD Contractor
Personnel in Africa
AFRICOM Conducts Limited Vetting of Contractors and
Contractor Employees and Does Not Have Guidance to Apply
Additional Risk-Based Measures
Conclusions
Recommendations for Executive Action
Agency Comments and Our Evaluation
28
37
38
39
Appendix I
Objectives, Scope, and Methodology
44
Appendix II
Comments from the Department of Defense
48
Appendix III
GAO Contact and Staff Acknowledgments
52
Related GAO Products
4
10
19
53
Table
Table 1: U.S. Africa Command (AFRICOM) Contractor Employee
Screening Measures Vary by Site
33
Figures
Figure 1: Value Associated with DOD Contracts in U.S. Africa
Command Area of Responsibility, Fiscal Years 20092014
Figure 2: Operational Contract Support Functions and Associated
Tasks
Figure 3: Operational Contract Support Integration Cell’s Staff
Integration Function within a Command
Page i
6
7
8
GAO-16-105 Operational Contract Support
Figure 4: Operational Contract Support Integration Cell Functions
at Different Levels of U.S. Africa Command
Figure 5: U.S. Africa Command Contractor Personnel
Accountability Processes
Figure 6: U.S. Africa Command’s Proposed Foreign Vendor
Vetting Process
Figure 7: Camp Lemonnier, Djibouti, Contractor Employee
Screening Process
13
22
31
35
Abbreviations
AFRICOM
DOD
OCS
SPOT
U.S. Africa Command
Department of Defense
Operational Contract Support
Synchronized Predeployment and Operational
Tracker
This is a work of the U.S. government and is not subject to copyright protection in the
United States. The published product may be reproduced and distributed in its entirety
without further permission from GAO. However, because this work may contain
copyrighted images or other material, permission from the copyright holder may be
necessary if you wish to reproduce this material separately.
Page ii
GAO-16-105 Operational Contract Support
441 G St. N.W.
Washington, DC 20548
December 17, 2015
The Honorable John McCain
Chairman
The Honorable Jack Reed
Ranking Member
Committee on Armed Services
United States Senate
The Honorable Mac Thornberry
Chairman
The Honorable Adam Smith
Ranking Member
Committee on Armed Services
House of Representatives
As major military operations wind down in Afghanistan, the Department of
Defense (DOD) continues to engage with partner nations in other regions
of the world, including Africa, and increasingly relies on contractors to
provide support for a range of activities such as security force assistance
and training. Since 2002 DOD has spent billions of dollars on contract
support for operations in Iraq and Afghanistan, and has taken steps to
address challenges regarding the planning, management, and oversight
of contractors in that region. 1 However, the conditions under which DOD
operates in Africa, such as having limited resources and extensive
distances between DOD locations across the continent, complicated by
efforts to counter violent extremist organizations in a noncombat zone,
create additional challenges in contract support planning and
management.
Accordingly, DOD’s U.S. Africa Command (AFRICOM) and its
subordinate commands must be familiar with how to plan for and
integrate operational contract support (OCS) into military operations and
activities. OCS is the process of planning for and obtaining supplies,
services, and construction from commercial sources in support of joint
1
Commission on Wartime Contracting in Iraq and Afghanistan, Transforming Wartime
Contracting: Controlling Costs, Reducing Risks (August 2011).
Page 1
GAO-16-105 Operational Contract Support
operations. 2 In our body of work on OCS, 3 we have reported that DOD
has long experienced challenges in managing OCS. For example, in our
2015 report highlighting high risk issues in the federal government, we
reported that DOD continues to face capacity shortfalls and lacks
performance measures to address operational contract support issues. 4
In February 2013 we reported that, with the exception of the Army, the
military services had not issued comprehensive service-specific guidance
that described roles, responsibilities, and requirements to help integrate
OCS into their planning efforts for contingency operations. 5 Further, in
June 2010 and again in September 2012 we testified on the need for a
cultural change in DOD that emphasizes an awareness of OCS
throughout the department to address the challenges faced in
contingency operations. 6 In recent years DOD and the Joint Staff have
issued and updated OCS guidance, discussing matters such as
identifying and planning for OCS requirements, OCS roles and
responsibilities, and processes for contractor personnel accountability. 7
House Report 113-446, accompanying a bill for the National Defense
Authorization Act for Fiscal Year 2015, included a provision for GAO to
2
Joint Chiefs of Staff, Joint Pub. 4-10, Operational Contract Support at GL-8 (July 16,
2014) (hereinafter cited as Joint Pub. 4-10 (July 16, 2014)). In a DOD regulation, the
department defines operational contract support as the ability to orchestrate and
synchronize the provision of integrated contract support and management of contractor
personnel providing support to the joint force within a designated operational area. 32
C.F.R. § 158.3; Department of Defense Instruction 3020.41, Operational Contract Support
(OCS) at 49 (Dec. 20, 2011).
3
See Related Products Page at the end of this report.
4
GAO, High-Risk Series: An Update, GAO-15-290 (Washington, D.C.: Feb. 11, 2015).
Every 2 years, in accordance with congressional elections, GAO calls attention to
agencies and program areas that are high risk due to their vulnerabilities to fraud, waste,
abuse, and mismanagement, or are most in need of transformation.
5
GAO, Warfighter Support: DOD Needs Additional Steps to Fully Integrate Operational
Contract Support Into Contingency Planning, GAO-13-212 (Washington, D.C.: Feb. 8,
2013).
6
GAO, Warfighter Support: Cultural Change Needed to Improve How DOD Plans for and
Manages Operational Contract Support, GAO-10-829T (Washington D.C.: June 29, 2010)
and Operational Contract Support: Sustained DOD Leadership Needed to Better Prepare
for Future Contingencies, GAO-12-1026T (Washington D.C.: Sept. 12, 2012).
7
See generally Department of Defense Instruction 3020.41, Operational Contract Support
(OCS) (Dec. 20, 2011); 32 C.F.R. pt. 158; Joint Pub. 4-10 (July 16, 2014).
Page 2
GAO-16-105 Operational Contract Support
examine matters related to OCS in Africa. 8 This report evaluates the
extent to which AFRICOM (1) has an organizational structure in place to
manage, plan for, and assess operational contract support; (2) accounts
for contractors in its area of responsibility; and (3) vets non-U.S.
contractors and contractor employees.
To address these objectives we reviewed relevant documents, including
DOD guidance, and interviewed officials in the Joint Staff and Office of
the Secretary of Defense, military services, AFRICOM, and its
subordinate commands; Special Operations Command Africa; and
Combined Joint Task Force-Horn of Africa. 9 We also conducted site visits
to three locations in Africa: (1) Navy-operated Camp Lemonnier in
Djibouti; (2) Air Force-operated Exercise Reception Facility in Niger; and
(3) multiple facilities operated by the Marine Corps and Special
Operations forces in Uganda. We selected these locations based on
variations in the military services represented, the types of contractor
personnel (U.S., third country, 10 and local national), and the types of
services provided. To determine the extent to which AFRICOM has an
organizational structure in place to manage, plan for, and assess OCS,
we conducted interviews and collected documentation from AFRICOM
headquarters and service component command officials. We also
evaluated all OCS readiness scorecards used by AFRICOM logistics
officials to measure subordinate commands’ OCS management
capabilities. To determine the extent to which AFRICOM accounts for
contractor personnel in its area of responsibility, we reviewed DOD,
AFRICOM, and Joint Staff personnel accountability guidance and
interviewed AFRICOM personnel officials, as well as military service
officials with personnel accountability responsibilities at the AFRICOM
sites that we visited on the continent. To determine the extent to which
AFRICOM vets contractors and contractor employees, we compared
DOD and AFRICOM guidance to information gathered from officials at
AFRICOM and on the continent regarding vendor vetting and contractor
employee screening processes. We also observed contractor screening
8
See H.R. Rep. No. 113-446, at 248-49 (2014).
9
AFRICOM and all of the service component command headquarters are located in
Europe. Combined Joint Task Force-Horn of Africa is located at Camp Lemonnier,
Djibouti.
10
Third country national contractors are contractors who are not from the U.S. or the
country where the services are being provided, but rather from any other country.
Page 3
GAO-16-105 Operational Contract Support
and base access procedures at the sites in Djibouti, Niger, and Uganda.
The information gathered from these three sites, while not generalizable
to all AFRICOM sites, provides valuable insights about personnel
accountability, contractor vetting, and contractor employee screening
processes in the AFRICOM area of responsibility. Appendix I describes
our objectives, scope, and methodology in greater detail.
We conducted this performance audit from June 2014 to December 2015
in accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our audit objectives. We believe that
the evidence obtained provides a reasonable basis for our findings and
conclusions based on our audit objectives.
Background
AFRICOM is DOD’s newest geographic combatant command and was
designated fully operational in September 2008. The command’s area of
responsibility comprises all the countries on the African continent except
Egypt. According to AFRICOM officials, Camp Lemonnier, Djibouti, is the
only DOD site in Africa with a long-term use agreement, but AFRICOM
has established temporary facilities across the continent to house the
personnel and equipment used for security assistance, training, and other
operations in the region. AFRICOM is supported by its subordinate
commands: U.S. Army Africa, U.S. Naval Forces Africa, 11 U.S. Marine
Corps Forces Africa, U.S. Air Force Africa, and Special Operations
Command Africa. AFRICOM also has a subordinate joint force command,
Combined Joint Task Force-Horn of Africa, which conducts operations in
East Africa to enhance partner nation capacity, promote regional stability,
dissuade conflict, and protect U.S. and coalition interests. 12 U.S. Army
Africa has a dedicated military contracting element, the 414th Contracting
Support Brigade, which provides OCS planning assistance to U.S. Army
Africa and synchronizes and executes contracting solutions across the
11
In addition to U.S. Naval Forces Africa, three other Navy component commands engage
in contracting in the AFRICOM area of responsibility: the Navy Supply Systems Command
Fleet Logistics Center Sigonella; the Navy Expeditionary Combat Command, and the
Navy Facilities Engineering Command.
12
A subordinate joint force command is a joint force command—either a subordinate
unified command or joint task force command—that is subordinate to a combatant
command and exercises command authority or operational control over a joint force.
Page 4
GAO-16-105 Operational Contract Support
continent. AFRICOM’s subordinate commands are located in Europe and
do not have assigned forces, except for the joint task force, which is
located at Camp Lemonnier in Djibouti.
Since its establishment AFRICOM has increased its footprint on the
continent to support the command’s missions of building African partner
defense capabilities, responding to crises, and deterring transnational
threats in order to promote regional security. In tandem with AFRICOM’s
growing footprint there has been a continued reliance on contractors to
provide, among other things, logistical, transportation, and intelligence
support to the command’s missions. This reliance on contractors was
highlighted in September 2014 when AFRICOM supported the U.S.
Agency for International Development and Liberia under Operation United
Assistance in responding to the largest Ebola epidemic in history.
AFRICOM reported having approximately 5,600 personnel 13 on the
African continent in October 2014, of whom 569—approximately 10
percent—were U.S. citizen contractor personnel. Moreover, the dollar
value associated with DOD contracts in AFRICOM’s area of responsibility
more than doubled, from $147 million in fiscal year 2009 to $463 million in
fiscal year 2014. 14 While the dollar value associated with these contracts
decreased in most regions from fiscal year 2013 to fiscal year 2014 (see
figure 1), AFRICOM officials expect the need for contract support to
increase as regional instability and responsibilities for protecting U.S.
personnel and facilities continue.
13
These reported personnel were military, civilian, and U.S. contractor employees.
14
The dollar values represent the obligations associated with contracts awarded by the
Department of Defense in the Africa Command area of responsibility, according to a DOD
report using data from the Federal Procurement Data System and supplemented with data
from the Army Contracting Business Intelligence System in some cases.
Page 5
GAO-16-105 Operational Contract Support
Figure 1: Value Associated with DOD Contracts in U.S. Africa Command Area of Responsibility, Fiscal Years 2009-2014
Notes: The dollar values in the figure above represent the obligations associated with contracts
awarded by the Department of Defense (DOD) in the Africa Command (AFRICOM) area of
responsibility, according to a DOD report using data from Federal Procurement Data System and
supplemented with data from the Army Contracting Business Intelligence System in some cases.
a
Contract values from fiscal years 2012 to 2014 reflect approximately $600 million in military
construction projects at Camp Lemonnier, Djibouti, that according to DOD officials are scheduled to
be completed in fiscal years 2016-2017.
b
The data provided by DOD reflect a negative contract action obligation value in the Southern Africa
region in fiscal year 2010. According to AFRICOM, this was due to a canceled contract that resulted
in the funds being returned to DOD.
Page 6
GAO-16-105 Operational Contract Support
OCS Functions
OCS is the process of planning for and obtaining supplies, services, and
construction from commercial sources in support of joint operations. OCS
encompasses three functions: contract support integration, contracting
support, and contractor management. 15 These functions and their
associated tasks are described in figure 2.
Figure 2: Operational Contract Support Functions and Associated Tasks
Determining OCS requirements, as well as conducting the initial planning
for and coordination of these tasks, is primarily an operational, not a
contracting, function. As a result, all of the directorates within a command
have OCS roles or responsibilities, but the directorates may not fully
understand how to properly define requirements for and manage OCS. In
the 2014 update to Joint Publication 4-10 the Joint Staff introduced the
concept of an OCS Integration Cell as a central coordination point that
can, among other things, provide staff integration by assisting and
advising the directorates on these issues. Figure 3, based on information
from the Joint Staff, demonstrates the integrating role of an OCS
Integration Cell.
15
In the context of OCS, “contractor management” refers to the oversight and integration
of contractor personnel and associated equipment providing support to the joint force in a
designated operational area. 32 C.F.R. § 158.3; Joint Pub. 4-10, at I-3 (July 16, 2014).
Page 7
GAO-16-105 Operational Contract Support
Figure 3: Operational Contract Support Integration Cell’s Staff Integration Function within a Command
Notes: DOD’s combatant commands are typically organized into directorates (designated as Js in the
figure). This is a general depiction of a combatant command’s structure; individual structures may
vary.
Contractor Personnel
Accountability
Personnel accountability is generally the process by which the geographic
combatant command identifies, captures, and records information—
usually through the use of a database—about the number and type of
personnel, including contractor personnel, in its area of operations.
DOD’s Synchronized Predeployment and Operational Tracker (SPOT)
was developed to assist the combatant commander in ensuring that
Page 8
GAO-16-105 Operational Contract Support
accountability, visibility, force protection, medical support, personnel
recovery, and other related support can be accurately forecasted and
provided for the contractor personnel in the command’s area of
responsibility. SPOT contains personnel accountability data only for
contractor personnel (U.S. citizen, third country, and local national), not
military or civilian personnel. When specified by contract, vendors are
responsible for inputting and maintaining their employees’ personnel data
in SPOT throughout the employees’ periods of performance. SPOT and
service-specific accountability systems typically feed information into
DOD’s accountability system to produce joint personnel status reports.
Vendor Vetting and
Contractor Employee
Screening
DOD contracting officers are required to check prospective contractors’
names against a list of prohibited, restricted, or otherwise ineligible
entities in a U.S. government contracting database called the System for
Award Management. 16 The prohibited entities list in the System for Award
Management contains sanctioned and other prohibited entities identified
by the Department of Treasury, Department of State, DOD, and other
U.S. agencies. A foreign vendor vetting cell can also be established to vet
selected local national and third county national companies so as to
prevent DOD from awarding contracts to companies having ties to violent
extremist organizations or other inappropriate entities. The vetting
consists of researching the principal owners and connections of the
company using information provided by owners, and then cross-checking
this information against various intelligence sources.
Subordinate and individual base commanders are responsible for the
security of military facilities within the combatant commander’s area of
responsibility. A contractor employee screening process mitigates the
potential security risk that third country and local national contractor
personnel may pose when they have access to DOD facilities. While
there is no standard DOD methodology for contractor employee
screenings overseas, a background investigation or similar process to
16
See Class Deviation 2014-O0020, Prohibition on Contracting with the Enemy (Sept. 17,
2014); 48 C.F.R. (FAR) § 9.405(d). After a draft of this report was sent to DOD for
comment, DOD issued Class Deviation 2015-O0016 in September 2015, which
superseded Class Deviation 2014-O0020. The new guidance retained the requirement for
contracting officers to check the prospective contractors’ names against the list. See Class
Deviation 2015-O0016, Prohibition on Providing Funds to the Enemy and Authorization of
Additional Access to Records, attachment 3 (Sept. 15, 2015).
Page 9
GAO-16-105 Operational Contract Support
confirm the trustworthiness of contractor personnel should be conducted
to the greatest extent possible. 17
AFRICOM Has
Established an
Organizational
Structure to Manage,
Plan for, and Assess
OCS, but Some
Subordinate
Commands Have Not
Done So
AFRICOM established a formal OCS structure with dedicated
personnel—including an OCS Integration Cell—at the headquarters level
to serve as the central coordination point to integrate OCS in all
directorates, and to manage, plan for, and assess OCS. However, only
one of AFRICOM’s subordinate commands has an organizational
structure in place with dedicated personnel to manage and plan for OCS.
Furthermore, AFRICOM has developed a scorecard to assess OCS
capabilities at the subordinate command level, but portions of each
assessment of the six subordinate commands have been inaccurate
because it is unclear how the performance measures in scorecards
should be applied.
AFRICOM Has
Established an
Organizational Structure to
Manage and Plan for OCS
AFRICOM headquarters’ establishment of a formal OCS organizational
structure began in 2011 with three dedicated DOD civilian personnel to
oversee OCS activities in Africa. Since that time, several notable OCS
milestones have been achieved, such as the establishment of an OCS
Integration Cell for the command’s headquarters in early 2014. According
to Joint Publication 4-10, an OCS Integration Cell should be established
as a permanent cell at the geographic combatant command level. The
primary function of the cell is to conduct general OCS planning, provide
advice, promote coordination, and maintain a common OCS operating
picture. 18 In 2015 AFRICOM headquarters expanded its OCS Integration
Cell from three dedicated civilian personnel to five who work alongside
two preexisting OCS planners from the Defense Logistics Agency’s Joint
Contingency Acquisition Support Office, according to AFRICOM officials.
AFRICOM directorates also participate in facilitating OCS. For example,
AFRICOM’s personnel directorate is tasked with maintaining personnel
accountability throughout the area of responsibility. AFRICOM also has
boards and working groups dedicated to coordinating OCS activities,
including a board that synchronizes and optimizes OCS during all phases
17
See Department of Defense Instruction 2000.16, DOD Antiterrorism (AT) Standards,
encl. 3, para. E3.18.2 (Oct. 2, 2006) (incorporating change Dec. 8, 2006).
18
See Joint Pub. 4-10, at III-3 to III-4 (July 16, 2014).
Page 10
GAO-16-105 Operational Contract Support
of operation. Participants in these boards and working groups include
members of the OCS Integration Cell, such as the Joint Contingency
Acquisition Support Office planners assigned to the combatant command,
as well as staff from the combatant command, service component
commands, and other combat support agencies.
AFRICOM’s OCS Integration Cell has also taken steps to manage OCS
at its subordinate commands by conducting staff assistance visits to
enhance OCS capabilities. Specifically, since March 2014, AFRICOM
OCS Integration Cell officials have conducted staff assistance visits to all
of AFRICOM’s service component commands as well as to Special
Operations Command Africa and Combined Joint Task Force-Horn of
Africa. The purpose of these visits is to assist and partner with
subordinate commands to ensure that current AFRICOM processes,
policies, tools, and procedures for OCS align with DOD policy and joint
doctrine, and to enhance mission execution. Additionally, staff assistance
visits help AFRICOM officials to gain a better understanding of OCS
procedures and challenges at the subordinate commands. Common
observations that have been made during such visits include noting a lack
of standardized OCS organization at the subordinate command levels,
noting constrained subordinate command resources for managing OCS,
and noting a lack of OCS training. AFRICOM officials stated that they
intend to work with the subordinate commands to address these issues.
However, these officials did not provide details or a plan for how they
were to work with the subordinate components.
AFRICOM’s OCS Integration Cell also plays a key role in planning for
OCS by working with operational planners to incorporate OCS concepts
into planning documents. For example, according to officials, the OCS
Integration Cell assisted AFRICOM’s planning directorate officials in
developing OCS annexes for several concept plans, as well as the
theater and regional campaign plans. These OCS annexes generally
contained key considerations discussed in Joint Staff and other DOD
guidance related to OCS, such as force protection, host nation
agreements, and contractor oversight.
AFRICOM OCS Integration Cell officials also developed a template for
subordinate commands to use as they begin to develop their own OCS
planning documents, including OCS annexes to plans and orders when
needed. The OCS planning template is meant to guide AFRICOM
subordinate commands in OCS planning for operations, exercises,
security cooperation activities, and other initiatives. It contains 20 steps,
including identifying mission length and requirements, leveraging
Page 11
GAO-16-105 Operational Contract Support
historical contracts, developing acquisition and cross-servicing
agreements, researching vendors, and identifying other factors that may
impact OCS.
Most AFRICOM
Subordinate Commands
Have Not Established an
OCS Organizational
Structure
With the exception of U.S. Army Africa, AFRICOM’s subordinate
commands, including service component and joint force commands,
generally lack formal organizational structures with personnel dedicated
to OCS. Joint Publication 4-10 notes that OCS Integration Cells can be
established at the service component and subordinate joint force
command levels. Specifically, Joint Publication 4-10 indicates that each
service component command determines, based on specific operational
requirements, whether it should establish an OCS Integration Cell. For
details about the functions of OCS Integration Cells at the combatant
command, component command, and joint force command levels, see
figure 4.
Page 12
GAO-16-105 Operational Contract Support
Figure 4: Operational Contract Support Integration Cell Functions at Different
Levels of U.S. Africa Command
Note: Operation United Assistance refers to DOD’s counter-Ebola effort in West Africa in fall 2014. As
part of this operation, AFRICOM set up a Joint Force Command headquartered in Monrovia, Liberia,
to provide regional support to U.S. military activities and facilitate coordination with U.S. government
and international relief efforts.
U.S. Army Africa has established an organizational structure with
dedicated full-time OCS personnel employed within the logistics
directorate. 19 This OCS Cell works with planners to incorporate OCS
19
While U.S. Army Africa does not consider these personnel to constitute an OCS
Integration Cell, the division provides the same OCS-coordinating function as an OCS
Integration Cell.
Page 13
GAO-16-105 Operational Contract Support
concepts into planning documents. U.S. Army Africa’s OCS Cell has also
issued OCS guidance, which outlines OCS roles and responsibilities,
including those related to development of contract requirements; OCS
programs and procedures; and intra-theater cooperation with other
component commands. Additionally, U.S. Army Africa’s dedicated military
contracting element—414th Contracting Support Brigade—provides OCS
planning assistance to U.S. Army Africa. While U.S. Naval Forces Africa,
U.S. Air Force Africa, and U.S. Marine Corps Forces Africa do not have
formalized OCS organizational structures, all of the service component
commands participate in AFRICOM’s OCS-related working groups. In
addition, Marine Corps Forces Africa has designated one official in its
logistics directorate to serve as the component command’s OCS chief,
but according to Marine Corps officials, this official is also responsible for
OCS policy and coordination in the European Command area of
responsibility. U.S. Air Force Africa and U.S. Naval Forces Africa 20 have
not established OCS organizational structures or dedicated OCS
personnel.
While joint staff guidance does not require the establishment of an OCS
Integration Cell or dedicated OCS personnel at the service component
command level, joint staff has emphasized the benefits of using an OCS
Integration Cell to synchronize requirements and coordinate contracting
actions. Moreover, Navy contracting officials stated that contract
requirements are not always clear, and if they do not have the statements
of work from the requiring activity at an early stage, they may not know
what is needed before the forces arrive on the ground. As a result,
operations might be delayed or might be carried out without sufficient
equipment or support services. An OCS Integration Cell or similar
structure with dedicated OCS personnel at the other service component
commands could help identify contract support issues early in the
requirements development process, thereby enabling the commands to
avoid delays. For example, U.S Army Africa’s dedicated OCS personnel
and the 414th Contracting Support Brigade have corrected potential
issues regarding poor coordination of contracts. U.S. Army Africa officials
stated that an Army unit may fail to inform contracting officials about what
equipment they are bringing along on deployment, or may disregard
20
In addition to the U.S. Naval Forces Africa, three other Navy component commands
engage in contracting in the AFRICOM area of responsibility: the Navy Supply Systems
Command Fleet Logistics Center Sigonella, the Navy Expeditionary Combat Command,
and the Navy Facilities Engineering Command.
Page 14
GAO-16-105 Operational Contract Support
training on how to properly draft a performance work statement. The
414th Contracting Support Brigade will incorporate these missing details
into the contracts based on previous experience with units requiring
similar services or goods.
U.S. Naval Forces Africa, U.S. Marine Corps Forces Africa, and U.S. Air
Force Africa logistics officials stated that one of their challenges is the
limited number of personnel who are available to be dedicated to OCS. In
our February 2015 report on high risk issues, we reported that DOD
continues to face capacity shortfalls for addressing OCS issues. 21
Funding and staffing constraints may prevent the establishment of an
OCS Integration Cell at the service component command level. Joint
Publication 4-10 recognizes that the establishment of an OCS Integration
Cell or similar structure at the service component command level will vary
based on specific operational requirements. Joint guidance also indicates
that there is no set structure or size for an OCS Integration Cell at any
command level; size and configuration are mission-dependent, and a cell
could be as small as two individuals or could be significantly larger,
depending on the operation. Air Force Africa and Navy Africa officials also
cited a lack of service guidance as an impediment to establishing an OCS
organizational structure.
An OCS Integration Cell was established at AFRICOM’s subordinate joint
force command supporting Operation United Assistance in 2014, but not
at the Combined Joint Task Force-Horn of Africa at Camp Lemonnier,
Djibouti, or Special Operations Command Africa. 22 Joint Publication 4-10
indicates that an OCS Integration Cell is normally established at the
subordinate joint force command level, where it leads general OCS
planning, provides advice, promotes coordination of OCS matters, and
maintains an OCS common operating picture, among other tasks. 23 As of
January 2015, according to officials, Combined Joint Task Force-Horn of
Africa had two officials in the contingency contracting office and one
logistics official who received OCS training. Officials further stated that
Combined Joint Task Force-Horn of Africa plans to dissolve its
21
GAO-15-290
22
Joint Publication 1 indicates that a joint task force is a type of joint force command. See
generally Joint Chiefs of Staff, Joint Pub. 1, Doctrine for the Armed Forces of the United
States, ch. IV (Mar. 23, 2013).
23
Joint Pub. 4-10, at III-7, D-4 to D-7 (July 16, 2014).
Page 15
GAO-16-105 Operational Contract Support
contingency contracting office entirely by the end of fiscal year 2016, as it
transitions to a more enduring presence at Camp Lemonnier, Djibouti.
DOD officials stated that there are plans to create two dedicated OCS
positions within the Combined Joint Task Force-Horn of Africa’s logistics
directorate. As dedicated personnel, these officials could carry out some
OCS coordinating tasks and could frequently communicate with logistics,
operations, and planning officials about OCS issues. However, an OCS
Integration Cell would provide a permanent centralized coordination point
within the joint environment at Camp Lemonnier. Furthermore, this type of
coordination will be increasingly important in the future, as DOD develops
a more enduring joint presence at Camp Lemonnier.
At the subordinate joint force command level, joint guidance provides that
an OCS Integration Cell should normally exist, depending on mission
conditions, but the guidance does not specify those conditions. As a
result, there is no clear guidance directing Combined Joint Task ForceHorn of Africa or Special Operations Command Africa to establish an
OCS Integration Cell. An OCS Integration Cell or similar structure would
be particularly useful in a joint environment due to the number of military
service contracting elements operating at one location with potentially
limited resources. According to Combined Joint Task Force-Horn of Africa
contracting officials, applying OCS concepts such as establishing an OCS
Integration Cell at Camp Lemonnier would be helpful to avoid duplication
of work and increased costs. For example, there are multiple car rental
contracts for different service components located at Camp Lemonnier,
Djibouti. Combined Joint Task Force-Horn of Africa contracting officials
stated that if they had all contracted with one vendor they would have
gotten a better price. As another example, officials at Camp Lemonnier
stated that some military service tenants have arrived without previously
informing the Navy as the Lead Service for Contracting at Camp
Lemonnier about the number of contractor personnel accompanying
them. Without prior coordination, Navy officials do not know how much
housing, food, and fuel they require at the base. Special Operations
Command Africa officials stated that the contract requirements
development process can be haphazard, and that logistical planners are
often brought into the process later than necessary. An OCS
organizational structure or dedicated OCS personnel could ensure that
OCS requirements are considered and clarified well before operations
have begun.
Page 16
GAO-16-105 Operational Contract Support
AFRICOM Developed a
Tool to Assess
Subordinate Commands’
OCS Capabilities, but
Assessments Do Not Fully
Reflect Subordinate
Command Performance
In May 2013 AFRICOM developed and began utilizing OCS Readiness
Scorecards to systematically assess its subordinate commands’ progress
in managing OCS. The scorecards document how well OCS is being
incorporated into the subordinate commands’ planning documents,
organizational structures such as boards and working groups, training
exercises, and accountability processes. To that end, the scorecards
comprise 32 OCS tasks divided among four broad categories: (1)
compliance (planning, administration, and training); (2) boards and
working groups; (3) exercises; and (4) common operating picture/SPOT.
The command’s OCS Integration Cell rated each subordinate command
as being either compliant, partially compliant, or non-compliant for each
component task, based on OCS Integration Cell officials’ determination
about the subordinate command’s progress toward completing that task.
For example, according to U.S. Army Africa’s May 2014 OCS readiness
scorecard, personnel had received training for contracting officer’s
representatives prior to their deployment, so it was rated as compliant for
this task. According to AFRICOM officials, the scorecards provide an
overall picture of subordinate commands’ OCS capabilities, promote
collaboration on OCS issues, and identify timely OCS training
requirements and activities.
However, we found that AFRICOM’s assessments do not fully reflect the
extent to which subordinate commands have completed or not completed
OCS tasks. Specifically, in three of AFRICOM’s scorecard assessments it
listed the subordinate command as complying with a task, when the
subordinate command had not accomplished that task. For example, one
component task is to incorporate OCS-specific tasks into exercises.
AFRICOM assessed Air Force Africa as compliant on this task. However,
Air Force Africa officials stated that they did not participate in any
exercises during the assessment time period, so they did not incorporate
OCS tasks into exercises. In another example, Special Operations
Command Africa officials stated that they had processes for awarding
contracts, but they lacked standard processes for incorporating OCS into
planning and requirements determinations. However, AFRICOM listed
Special Operations Command Africa as possessing standardized
processes for support units and activities because the scorecard does not
specify that these processes should specifically involve the incorporation
of OCS into planning and requirements development.
Furthermore, AFRICOM applied different standards of compliance to
different subordinate commands. For example, one component task
focuses on contractor accountability through the utilization of SPOT, a
contractor personnel accountability database. AFRICOM assessed
Page 17
GAO-16-105 Operational Contract Support
Marine Forces Africa as partially compliant with its contractor
accountability guidance, and all other components as fully compliant.
However, AFRICOM officials stated that no subordinate command had
processes in place to ensure that contractor personnel were being
included in SPOT—a contractor accountability database—at the time of
the assessment, and that AFRICOM contractor personnel accountability
guidance was unclear about when the commands were required to
account for contractor personnel, and what types of contractor personnel
to include. While AFRICOM did not penalize the subordinate commands
for non-compliance when the guidance they need to comply with is
unclear, the scorecards did not clarify how to assess subordinate
commands under these conditions. As a result, the assessment officials
inconsistently applied the assessment standards.
According to GAO’s performance measure evaluation guidance,
performance measures should be objective and performance data should
be accurate and consistent. According to AFRICOM’s OCS Instruction,
AFRICOM logistics officials are tasked with conducting periodic reviews
or inspections of AFRICOM staff and component commands to ensure
compliance with required OCS tasks. 24 In addition, Standards for Internal
Control in the Federal Government state that control activities need to be
established to monitor performance measures and indicators, and that
these activities should be effective and efficient in accomplishing
objectives. 25 Moreover, according to GAO best practices in performance
measurement, agency officials need to ensure that performance data are
complete, accurate, and consistent enough to document performance and
support decision-making at various organizational levels. 26 Further, to the
greatest extent possible, performance goals and measures should not
require subjective considerations or judgments to dominate the
measurement. 27
24
U.S. Africa Command Instruction 4800.01A, Operational Contract Support (OCS), para.
6.a(19) (May 1, 2012).
25
GAO, Standards for Internal Control in the Federal Government (Washington, D.C.:
November 1999).
26
GAO/GGD-96-118 Executive Guide: Effectively Implementing the Government
Performance and Results Act (Washington, D.C.: June 1996).
27
GAO/GGD-10.1.20, Results Act: An Evaluator’s Guide to Assessing Agency Annual
Performance Plans (Washington, D.C.: April 1998).
Page 18
GAO-16-105 Operational Contract Support
AFRICOM’s assessments do not accurately reflect subordinate command
OCS capabilities in that its assessment standards are unclear. In
explaining the errors contained within the scorecards, AFRICOM officials
who conducted the scorecard evaluations stated that they gave the
subordinate commands the benefit of the doubt for certain tasks,
particularly those for which guidance was unclear. AFRICOM officials
further stated that the scorecard process is maturing, that there are
several component tasks in the scorecards that they realize need
improvement or clarification, and that the future Theater Campaign Plan
will provide clearer explanations of the component tasks in terms of
compliance and OCS planning. However, AFRICOM officials stated that
they are in the process of updating the Theater Campaign Plan and did
not give a timeframe for completion.
Without clearly defined assessment standards for the scorecard,
AFRICOM cannot accurately assess the OCS actions taken by
subordinate commands. The lack of accurate assessments threatens the
integrity of those measures and undermines their value in promoting
progress in OCS management. Furthermore, AFRICOM officials stated
that they plan to incorporate OCS scorecards into the Defense Readiness
Reporting System, the system used to gauge readiness across DOD.
Without improvements, either full or partial incorporation of the scorecard
assessments into DOD’s readiness reporting system could compromise
the integrity of that system by capturing an inaccurate picture of OCS
readiness.
AFRICOM Cannot
Comprehensively
Account for DOD
Contractor Personnel
in Africa
Contractors in Africa provide a variety of services in support of U.S.
military operations, such as transportation, construction, and food
services, and officials expect the number of contractor personnel on the
continent to increase. However, AFRICOM does not have a complete
picture of the number of contractor personnel supporting its operations in
the region. AFRICOM uses two primary sources—daily personnel status
reports 28 and SPOT, a DOD contractor personnel accountability
database—to collect contractor personnel accountability information, but
neither source provides comprehensive accountability or visibility of DOD
28
We refer to the personnel reports that each subordinate command compiles to send to
AFRICOM as personnel status reports. The reports AFRICOM then compiles from the
subordinate commands to send to the Joint Staff are referred to as joint personnel status
reports.
Page 19
GAO-16-105 Operational Contract Support
contractor personnel on the continent because the total number of local
national contractor personnel are not being included in either, and
because the numbers of U.S. citizen and third country national contractor
personnel vary between the two.
Contractors Provide a
Variety of Services to
Support U.S. Military
Operations in Africa and
AFRICOM Expects to
Increase Its Reliance on
Them
According to SPOT data, which account for some but not all contractor
personnel, the number of contractor personnel in Africa is more than
1,130—a nine-fold increase since April 2011. DOD contractor personnel
perform a variety of functions and services to support mission needs,
including transportation, linguistics, engineering, construction, cleaning,
and food services. For example, in November 2014 AFRICOM reported
approximately 300 U.S. contractor personnel included in SPOT as
supporting Operation United Assistance in Senegal and Liberia. The
contractor services primarily consisted of construction and engineering of
training and medical units, and basic life support for troops, such as food
and janitorial services. AFRICOM also reported approximately 350 U.S.
contractor personnel at Camp Lemonnier, Djibouti, in October 2014
through its daily personnel status reports. These contractor personnel
performed a number of functions, including transportation, engineering,
and construction.
AFRICOM officials expect the number of contractor personnel on the
continent to continue to increase. Plans for expansion at Camp
Lemonnier in 2015 include numerous projects to increase capacity such
as expansion of emergency troop housing, taxiway extension, living and
working quarters, aircraft loading areas, and upgrades to existing power
plant capabilities. Although AFRICOM officials stated that they expect the
number of contractors at Camp Lemonnier to decrease over time as
construction is completed, they also stated that they expect the total
number of contractor personnel on the African continent to continue to
increase and shift from location to location as missions evolve,
particularly with regard to special operations. For example, officials from
Special Operations Command Africa stated that they are experiencing a
significant increase in contracting actions for Combined Joint Task ForceHorn of Africa and that plans are in place to add 10 contingency
contracting officers to Special Operations Command Africa for fiscal year
2016. Officials stated that it is extremely important to integrate OCS into
planning for the base’s expansion. Due to the austere environment,
officials stated that they intend to rely on contracted solutions because
they are more cost-effective than using military personnel.
Page 20
GAO-16-105 Operational Contract Support
AFRICOM Generally
Accounts for U.S. Citizen
Contractor Personnel but
Does Not Consistently
Account for Third Country
and Local National
Contractor Personnel
AFRICOM generally accounts for U.S. citizen contractor personnel, but it
accounts for third country and local national contractor personnel
inconsistently. AFRICOM uses two sources to capture accountability
information on contractor personnel supporting DOD operations—daily
personnel status reports from the services, and SPOT. According to
AFRICOM guidance, military service components, joint task forces, subunified commands, and forward operating sites in the AFRICOM area of
responsibility are responsible for accounting for all military, DOD civilian,
and DOD contractor personnel assigned, attached to, or under their
operational control, and they must submit a daily personnel status report
to AFRICOM personnel officials via email. 29 This information is also to be
inputted into military service personnel accountability systems. DOD’s
personnel accountability system—Joint Personnel Accountability
Reconciliation and Reporting (JPARR)—receives information from
various sources, including service-specific accountability databases and
SPOT, and generates Joint Personnel Status Reports. AFRICOM
personnel officials stated that they have not yet implemented JPARR and
are instead using daily personnel status reports from the services via
email and SPOT to manually develop Joint Personnel Status Reports and
account for contractor personnel. For a depiction of both AFRICOM’s
daily personnel status report and SPOT accountability processes, see
figure 5.
29
See U.S. Africa Command Instruction 1700.05A Personnel Management, (Apr. 4, 2012).
Page 21
GAO-16-105 Operational Contract Support
Figure 5: U.S. Africa Command Contractor Personnel Accountability Processes
Note: The requirement to register contractor personnel in SPOT is incorporated into the company’s
contract depending on the conditions of the support being provided.
Page 22
GAO-16-105 Operational Contract Support
Daily Personnel Status Reports
Account for Third Country and
Local National Contractor
Personnel Inconsistently
AFRICOM’s daily personnel status reports generally account for U.S.
citizen contractor personnel, but they account for third country and local
national contractor personnel inconsistently. AFRICOM officials generally
rely on daily personnel status reports from service components via email
to provide visibility on the number of personnel on the continent, including
the number of contractor personnel. These reports generally account for
U.S. contractor personnel, but they do not consistently include local or
third country national contractor personnel, or certain U.S. citizen
contractor personnel not directly assigned to a U.S. installation. For
example, the 414th Contracting Support Brigade in Uganda accounts for
local and third country national contractor personnel in its daily personnel
status report, but daily personnel status reports from the Air Force in
Niger do not. In addition, AFRICOM’s daily personnel status reports do
not include some U.S. contractor personnel who are not directly working
on U.S. installations in a given country. For example, personnel recovery
contractor personnel in Niger are not being accounted for in daily
personnel status reports because, according to officials, they do not live
on the installation.
DOD guidance indicates that combatant commands are to establish
policies and procedures to account for contractor personnel. Joint
Publication 4-10 indicates that a key to success in contractor
management is for geographic combatant commands and subordinate
joint force commands to establish clear, enforceable, and well-understood
contractor personnel accountability policies and procedures early in the
planning stages. The guidance notes that the supported commands must
work closely with service components to ensure that proper contract and
contractor management oversight is in place. 30 The guidance further
states that contractor personnel visibility and accountability are essential
to determine and provide the needed resources for government support
requirements such as life support, force protection, and personnel
recovery in uncertain or austere operational environments. Moreover,
Chairman of the Joint Chiefs of Staff policy and guidance on personnel
accountability 31 states that the joint personnel status reports developed by
combatant commanders are meant to satisfy the commander’s
information needs and to authenticate the total number of personnel,
30
See Joint Pub. 4-10, at V-3 (July 16, 2014).
31
Chairman of the Joint Chiefs of Staff Manual 3150.13C, Joint Reporting Structure—
Personnel Manual (Mar. 10, 2010) (current as of Nov. 6, 2012).
Page 23
GAO-16-105 Operational Contract Support
including military, DOD civilian, and DOD contractors, who are physically
present in a geographic combatant commander’s area of responsibility.
Under the policy and guidance, the geographic combatant commander is
responsible for reporting the total number of personnel, including DOD
contractors, via joint personnel status report to the Joint Staff personnel
directorate daily via secure website.
However, this guidance is unclear as to what types of contractors should
be accounted for in the joint personnel status report. The Chairman of the
Joint Chiefs of Staff guidance identifies SPOT as the designated webbased contractor database and lists the types of contractor personnel
included in SPOT—including U.S., local national, host nation, and third
country national—but it does not clearly specify the types of contractor
personnel to report in the daily personnel status report. 32 AFRICOM
officials stated that they interpreted this guidance as directing them to
account only for U.S. citizen contractor personnel in the daily personnel
status reports. Conversely, service component officials at some forward
operating sites included both third country and local national, as well as
U.S. citizen, contractor personnel in their personnel status reports sent to
AFRICOM. AFRICOM guidance indicates that personnel status reports
should include all military, civilian, and contractor personnel assigned,
attached, or under the operational control of the service component, subunified command, joint task force, or forward operating site commander. 33
However, AFRICOM guidance does not specify whether these contractor
personnel include third country or local national contractor personnel such
as linguists, or U.S. citizen contractor personnel who are under the
operational control of the local commander but do not live on the
installation. In addition, AFRICOM officials stated that while they receive
daily personnel status reports from all of the services, they do not have
complete information on how each of the services is collecting this
information. Without consistently recording the number of contractor
personnel in personnel status reports, AFRICOM cannot comprehensively
32
See id., encl. A, para. 2.a(10); encl. E, para. 13. See generally id., encl. A. The guidance
also identifies SPOT as the source of DOD-funded contractor “JPERSTAT-type”
information for a geographical combatant command (using the acronym for the joint
personnel status report). See id., para. 6.b(3). However, even assuming that a combatant
commander uses SPOT to account for each type of contractor personnel (including host
nationals), the guidance is not explicit as to whether each type must be reported in the
joint personnel status report itself.
33
See U.S. Africa Command Instruction 1700.05A Personnel Management (Apr. 4, 2012).
Page 24
GAO-16-105 Operational Contract Support
account for contractor personnel on the continent. Thus, revising the
Chairman of the Joint Chiefs of Staff and AFRICOM policy and guidance
on personnel accountability to clearly specify the types of personnel to be
accounted for in the joint personnel status report would provide
AFRICOM with better assurance that its staff consistently provides it with
comprehensive information.
Contractors Are Not
Consistently Accounting for
Their Employees in SPOT
We found that not all contractors consistently accounted for their
employees in SPOT. Specifically, contractors at two of the three sites we
visited are not reporting third country national and local national
employees in SPOT. For example, the contractor that manages the
primary logistics contract in Uganda reported U.S. citizen, third country,
and local national contractor personnel in SPOT in January 2015, but
another contractor that manages the primary base services contract at
Camp Lemonnier, Djibouti, accounted for U.S. citizen, third country, and
local national contractor personnel only in its company systems and not in
SPOT. DOD contracting officials subsequently modified the primary base
services contract for Camp Lemonnier to include a SPOT accountability
requirement specific to Djibouti. Officials from the primary base services
company at Camp Lemonnier stated that they have plans to report U.S.
citizen and third country national employees in SPOT, but they did not
provide a timeframe for doing so. In addition, according to Camp
Lemonnier officials, construction contractors building facilities at the site
do not account for their U.S. citizen, third country, and local national
contractor personnel in SPOT and do not have plans for doing so.
Various provisions in guidance cover the use of SPOT to account for
contractor personnel. 34 In December 2014 AFRICOM issued an interim
policy for the use of SPOT to account for and maintain visibility of
contractor personnel in the AFRICOM area of responsibility. 35 The
guidance states that AFRICOM requires the use of SPOT, or its
34
See, e.g., Department of Defense Instruction 3020.41, Operational Contract Support
(OCS), encl. 2, para. 3.c (Dec. 20, 2011); 32 C.F.R. § 158.6(c)(3); 48 C.F.R. (DFARS) §
252.225-7040(g). See also Chairman of the Joint Chiefs of Staff Manual 3150.13C, Joint
Reporting Structure—Personnel Manual, encl. E, para. 13 (Mar. 10, 2010) (current as of
Nov. 6, 2012) (identifying SPOT as the central repository for data on all DOD funded
contractor personnel—United States, local national, host nation, and third country
national).
35
U.S. Africa Command Notice 4800.01, Cancellation of ACI 4800.02A, Use of
Synchronized Pre-deployment and Operational Tracker (SPOT) in the U.S. Africa
Command Area of Responsibility (AOR) (Dec. 12, 2014).
Page 25
GAO-16-105 Operational Contract Support
successor, to account for contractor personnel in all phases of operations.
It states that SPOT is to be used for all U.S. citizens and third country
nationals deploying to the area of responsibility, regardless of contract
dollar amount. SPOT is also to be used to report an aggregate count of all
local nationals on a monthly basis for contracts employing these
personnel with periods of performance longer than 30 days. 36 AFRICOM’s
OCS annex to the theater campaign plan indicates that SPOT should be
utilized to account for contractor personnel deploying to the area of
responsibility and that contracting agencies will direct contractors to input
required information, although it does not specify what type of contractor
personnel should be registered in SPOT in these provisions. 37 In addition,
guidance issued by DOD directs the use of clauses that would require
contractors to use SPOT to account for certain contractor personnel
supporting DOD operations in Djibouti and in Operation United
Assistance. 38 However, we found that many of the contracts identified by
DOD as involving performance in Djibouti or in support of Operation
United Assistance did not contain the clauses. 39 Although DOD guidance
directs the inclusion of the clauses for new contracts providing supplies or
services in Djibouti and for Operation United Assistance, and modification
of existing contracts to the extent feasible, in some cases there may be a
good reason for omitting the clause. For example, if the contract is for
hotel lodging, it may not make sense to have hotel employees registered
in SPOT. In other contracts where the personnel will be directly
supporting operations at DOD facilities, such as those for construction or
base support, requiring the contractor to register its personnel in SPOT
would help AFRICOM to identify who is supporting its operations and for
whom it may be responsible in the event of an emergency.
36
SPOT is also to be used for all private security contracts. See id.
37
The guidance specifies use of SPOT to account for contractors authorized to
accompany the force in several provisions, but not in others.
38
See Class Deviation 2014-O0005, Requirements for Contractor Personnel Performing in
Djibouti (Jan. 13, 2014); Class Deviation 2015-O0003, Contractor Personnel Performing in
Support of Operation United Assistance in the United States Africa Command Theater of
Operations (Dec. 16, 2014).
39
In some instances, the contracts may have contained related clauses requiring the use
of SPOT for certain contractor personnel, such as DFARS § 252.225-7040. Although
these clauses include information related to SPOT accountability for certain contractor
personnel, it may not always be clear which contractor personnel they cover or whether
they apply in circumstances such as performance in Djibouti or during Operation United
Assistance.
Page 26
GAO-16-105 Operational Contract Support
AFRICOM personnel accountability guidance is unclear. As stated earlier,
Chairman of the Joint Chiefs of Staff guidance does not specify what
types of contractor personnel, such as U.S. citizen, third country national,
or local national, should be included in joint personnel status reports. In
addition, there are multiple provisions in guidance issued by different
sources, requiring the registration of different types of employees in
SPOT in various circumstances. Furthermore, AFRICOM’s interim
guidance generally requiring all contractor personnel in its area of
responsibility to be accounted for in SPOT expires in December 2015.
AFRICOM officials stated that they intend to request that this interim
guidance be included in an updated version of the Defense Federal
Acquisition Regulation Supplement. According to DOD officials, as of
October 2015, AFRICOM was in the final stages of drafting proposed
language to this effect. However, as of November 2015, there have been
no changes.
In March 2014, the AFRICOM commander stated that the command is
responsible for helping to protect U.S. personnel in Africa. 40 Without clear
accountability guidance, AFRICOM cannot consistently or
comprehensively determine how many contractor personnel support DOD
operations in the region. Without clarification and deconfliction of
guidance, AFRICOM and its subordinate commands will not know what
types of contractor personnel to include in personnel status reports and in
SPOT, and they could continue to account for these personnel
inconsistently. As a result, commanders are at risk of not having
comprehensive visibility over who is supporting DOD operations in the
area of responsibility. In addition, the AFRICOM area of responsibility lies
in an increasingly high threat environment. The Department of State has
identified 15 high threat posts on the continent. Without comprehensive
and consistent contractor personnel accountability, commanders may be
unaware of whom they are responsible for in the event of an emergency.
40
Statement of AFRICOM Commander General David M. Rodriguez, submitted to the
Senate Armed Services Committee, Mar. 6, 2014.
Page 27
GAO-16-105 Operational Contract Support
AFRICOM Conducts
Limited Vetting of
Contractors and
Contractor
Employees and Does
Not Have Guidance
to Apply Additional
Risk-Based Measures
AFRICOM conducts some limited vetting of potential contractors, also
referred to as vendors, but it has not established a foreign vendor vetting
process or cell that would preemptively identify vendors who support
criminal, terrorist, or other sanctioned organizations. Additionally, in
efforts to conduct individual contractor employee screening, AFRICOM
sites we visited used different types of background investigations to
determine the trustworthiness of contractor employees with access to
DOD facilities. However, these AFRICOM forward operating sites were
not incorporating additional screening measures, such as biometric
screening or counterintelligence interviews, according to the specific risks
at each site. As a result, AFRICOM is at risk of not exercising the
appropriate level of vendor vetting or contractor employee screening on
the African continent.
AFRICOM Conducts
Limited Vetting but
Does Not Have a
Foreign Vendor
Vetting Process to
Prevent Contracting
with Prohibited
Entities
AFRICOM conducts some limited vendor vetting, but it has not
established a foreign vendor vetting process. The Federal Acquisition
Regulation and DOD guidance require contracting officers to ensure that
they are not contracting with any prohibited entities by vetting potential
vendors’ names against a list of prohibited, restricted, or otherwise
ineligible persons or entities in the System for Award Management. 41 The
System for Award Management is a database used during the
procurement process that, among other things, provides information on
parties that are prohibited or restricted from receiving federal contracts. In
addition to information added by DOD, the database includes entities
identified by the Department of Treasury’s Office of Foreign Assets
Control, Department of State, and other U.S. agencies. All of the
AFRICOM service components with whom we conducted interviews
stated that their contracting officials do check the prohibited entities list in
the System for Award Management. However, as noted by Joint
Publication 4-10 in a related discussion, checking certain lists alone may
be insufficient. Specifically with respect to two lists maintained by the U.S.
41
See FAR § 9.405(d); Class Deviation 2014-O0020, Prohibition on Contracting with the
Enemy (Sept. 17, 2014). After a draft of this report was sent to DOD for comment, DOD
issued an updated Class Deviation in September 2015. Although the update may be more
limited in scope, generally covering contracts in support of contingency operations in
which members of the Armed Forces are actively engaged in hostilities, the requirement
for contracting officers to check the exclusions list does not explicitly include this limitation,
applying instead to contracts awarded on or before December 31, 2019, to be performed
outside the United States and its outlying areas. See Class Deviation 2015-O0016,
Prohibition on Providing Funds to the Enemy and Authorization of Additional Access to
Records, attachment 3 (Sept. 15, 2015).
Page 28
GAO-16-105 Operational Contract Support
Department of Treasury, Joint Publication 4-10 indicates that the
department has traditionally designated only umbrella organizations. 42 In
addition, officials from all of AFRICOM’s service components stated that
in their contracting process they use a list of vendors vetted by the local
U.S. embassy. However, U.S. Embassy and Department of State
headquarters officials stated that vendors on these lists are not vetted for
security risks or to determine whether they are connected to or supporting
any prohibited organizations; rather, they are vetted only for their ability to
provide the required services. As a result, AFRICOM’s current vetting
process is limited in its ability to ensure that DOD is not funding prohibited
organizations in high risk areas.
Current DOD guidance is not clear on what vendor vetting steps or
process should be established at each combatant command to mitigate
the risk of contracting with terrorist or other prohibited organizations. Joint
Publication 4-10 discusses the benefit of establishing a cell, when
circumstances warrant, to vet foreign vendors for possible security
concerns and avoid awarding contracts to companies that have ties to
insurgents. 43 However, the guidance does not require the establishment
of a vendor vetting cell or specify under what conditions it would be
appropriate. Two combatant commands—U.S. Transportation Command
and U.S. Central Command—have established foreign vendor vetting
cells for this purpose. Although AFRICOM does not have its own foreign
vendor vetting cell, during AFRICOM’s most recent contingency
operation—Operation United Assistance—AFRICOM requested
assistance from U.S. Transportation Command’s foreign vendor vetting
cell to provide threat assessments on all of the vendors that had been
awarded AFRICOM contracts. Although U.S. Transportation Command
was able to take on this additional workload, AFRICOM does not have a
written agreement to use that command’s vetting capability, and it may
not be able to leverage U.S. Transportation Command’s capabilities for
future contingencies.
In addition, AFRICOM may not be fully prepared to avoid contracting with
vendors who may also be supporting the enemy should it become actively
engaged in hostilities. In response to recent statutory provisions regarding
contracting with the enemy, DOD has issued guidance for geographic
42
See Joint Pub. 4-10, at III-22 (July 16, 2014).
43
See id. at III-27 to III-28.
Page 29
GAO-16-105 Operational Contract Support
combatant commands (with the exception of U.S. Northern Command) to
identify persons or entities who directly or indirectly provide funds,
including goods and services, received under covered contracts to person
or entities that are actively opposing U.S. or Coalition forces in a
contingency operation in which the armed forces are actively engaged in
hostilities. 44 According to DOD officials, the list of identified persons and
entities is integrated into the System for Award Management. As noted
above, the guidance also requires contracting officers to check this
database to ensure that contracts are not awarded to prohibited or
restricted persons or entities. According to officials, U.S. Central
Command is the only combatant command that is currently required to
proactively identify these vendors, organizations, and people and add
them to the prohibited entities list because it is the only combatant
command currently engaged in hostilities in a contingency environment.
Although AFRICOM does not currently have any declared contingency
operations involving active hostilities, it operates in a high threat
environment in which hostilities could quickly arise. Without having a
foreign vendor vetting process in place, it will be difficult for AFRICOM to
recognize and thereby avoid instances of contracting with the enemy.
AFRICOM officials agree that a foreign vendor vetting process would
reduce the risk that they would contract with prohibited entities, and they
have drafted guidance on establishing a foreign vendor vetting cell.
However, AFRICOM officials stated that they would need specific
guidance from the Office of the Secretary of Defense or Joint Chiefs of
Staff specifying the conditions under which combatant commands should
establish a vendor vetting cell to effectively implement this process. For a
description of AFRICOM’s current vendor vetting process and how it
would be supplemented by the establishment of the foreign vendor vetting
cell described in its draft guidance see figure 6.
44
See Class Deviation 2015-O0016, Prohibition on Providing Funds to the Enemy and
Authorization of Additional Access to Records, attachment 3 (Sept. 15, 2015). The
guidance implements section 841 of the Carl Levin and Howard P. “Buck” McKeon
National Defense Authorization Act for Fiscal Year 2015, Pub. L. No. 113-291 (2014) (10
U.S.C. § 2302 note). It superseded earlier guidance implementing provisions from the
National Defense Authorization Act for Fiscal Year 2014. See Class Deviation 2014O0020, Prohibition on Contracting with the Enemy (Sept. 17, 2014).
Page 30
GAO-16-105 Operational Contract Support
Figure 6: U.S. Africa Command’s Proposed Foreign Vendor Vetting Process
Note: AFRICOM’s proposed vendor vetting process would apply to solicitations or contract awards
with an estimated value in excess of $50,000 that would be performed using foreign vendors.
AFRICOM officials also cited resource limitations, specifically a shortfall in
intelligence analyst positions required for the proposed foreign vendor
vetting cell, as one of the challenges it faces to establishing a foreign
vendor vetting process. We have previously concluded that a risk-based
approach can help agencies strategically allocate limited resources to
Page 31
GAO-16-105 Operational Contract Support
achieve desired outcomes. 45 In 2011 we recommended that U.S. Central
Command consider a risk-based approach in identifying and vetting the
highest-risk foreign vendors. 46 In response to our recommendation, U.S.
Central Command established a formalized risk-based vetting program.
Its vetting process is designed to ensure that DOD funds are not used for
illicit purposes and to provide a risk management tool to identify foreign
vendors that have ties to the insurgency or that are involved in nefarious
activities. While the establishment of a foreign vendor vetting cell may not
be appropriate for all operations, published DOD guidance specifying
under what circumstances and how a vetting cell should be established
would better position AFRICOM and other commands to avoid contracting
with the enemy in high threat areas or in the event that they become
actively engaged in hostilities.
AFRICOM Sites That GAO
Visited Use Background
Investigations to Screen
Contractor Employees but
Lack Risk-Based
Guidance for Incorporating
Additional Screening
Measures
AFRICOM generally operates in a high threat area of responsibility, and
the screening of non-U.S. personnel entering AFRICOM facilities protects
DOD personnel, equipment, and installations from acts of espionage,
sabotage, or other intelligence activities. According to agency officials and
our observation of contractor personnel screening at the sites we visited,
all of the sites conduct some type of background investigation to screen
non-U.S. contractors, but Camp Lemonnier, Djibouti—the largest and
most enduring site in the AFRICOM area of operations—has the most
comprehensive screening process (see table 1 below). The other sites
that we visited have incorporated additional screening measures to
varying degrees.
45
For example, see GAO-11-144, Federal Lands: Adopting a Formal, Risk-Based
Approach Could Help Land Management Agencies Better Manage Their Law Enforcement
Resources, (Washington, D.C.: Dec. 17, 2010) and GAO-09-85, Commercial Vehicle
Security: Risk-Based Approach Needed to Secure the Commercial Vehicle Sector,
(Washington, D.C.: Feb. 27, 2009).
46
GAO-11-355, Afghanistan: U.S. Efforts to Vet Non-U.S. Vendors Need Improvement.
(Washington, D.C.: June 8, 2011).
Page 32
GAO-16-105 Operational Contract Support
Table 1: U.S. Africa Command (AFRICOM) Contractor Employee Screening Measures Vary by Site
Counterintelligence
b
interview
Biometric
c
screening
Document and
media
d
exploitation
Yes, conducted by
Department of
Defense (DOD)
Limited
Yes
Yes
Niger
Semi-enduring, Yes, conducted by
high threat
DOD and U.S.
embassy
Limited
No
Uganda
Semi-enduring, Yes, conducted by
high threat
U.S. embassy or
vendor
Limited
Limited to local
national drivers
Type of site,
threat level
Background
a
investigation
Djibouti
Enduring, high
threat
Site
f
e
Process generally
documented in
local guidance
Yes
No
No
No
No
g
Source: GAO analysis of DOD and State Department information | GAO-16-105
Notes:
a
A background investigation is the screening of contractors’ biographical information against local
criminal records and/or US terrorist watch lists and other intelligence databases.
b
A counterintelligence interview is an interview conducted to confirm the trustworthiness of the
contractor employee and the information provided for the background investigation.
c
Biometric screening is the screening of an individual’s physical characteristics, such as fingerprints or
irises, against a biometrically enabled watch list or other biometric intelligence database.
d
Document and media exploitation is the collection, analysis, and exploitation of captured equipment,
personal documents, and media to generate actionable intelligence.
e
In August 2014, Camp Lemonnier, Djibouti reinitiated contractor employee screening document and
media exploitation related operations after an 8 month gap.
f
Air Force officials at the Niger site received three biometric collection kits in Fall 2014, but two of
three kits broke soon after their arrival and the officials have since suspended biometric collection as
part of its contractor screening process.
g
The Air Force’s Niger site has local security guidance, but it does not describe the contractor
screening process currently in place.
Background Investigations
AFRICOM officials stated that all DOD sites in the AFRICOM area of
responsibility conduct background investigations for non-U.S. contractors
who require base access. All three sites that we visited use background
investigations to determine the trustworthiness of third country and local
national contractor employees who have access to DOD facilities.
Background investigations at the sites we visited generally consist of
gathering the contractor employee’s biographical information and
crosschecking it with U.S. government intelligence sources and against
local criminal records. However, the utility of these types of background
investigations is limited by the quality of (1) the biographic information
provided by the contractors, and (2) local government records, upon
which the investigations are based. For example, according to base
Page 33
GAO-16-105 Operational Contract Support
access officials, Djiboutian local national contractors are often able to
provide the year, but not the specific day and month, in which they were
born. In addition, at the sites we visited, DOD and Department of State
officials stated that local government criminal records in Africa may not be
easily searchable or well-maintained. As a result, additional contractor
employee screening measures may be warranted.
Additional Screening Measures
In light of the limitations of background investigations, additional
contractor employee screening measures, such as counterintelligence
interviews, biometric screening, and document and media exploitation,
are incorporated to varying degrees at the three sites we visited (see
table 1). For example, counterintelligence interviews with potential
contractor personnel can be used to confirm the trustworthiness of the
contractor employee and the information provided for the background
investigation. While all of the sites we visited conduct counterintelligence
interviews to varying degrees, according to DOD officials, none of them
conducts interviews with all of its non-U.S. contractor personnel.
Biometric screening is another measure that can be incorporated into the
contractor employee screening process. The collection of biometric
information, such as fingerprints or irises, unequivocally links the
individual’s identity by attaching it to measurable physical characteristics.
Officials can then screen this biometric information against a biometrically
enabled watch list or other intelligence database. In August 2009
AFRICOM issued a Biometrics Concept of Operations stating that, to the
maximum extent allowable under policy and law, persons requiring
access to DOD installations in the AFRICOM area of responsibility will be
enrolled into a biometrics database. 47 However, Camp Lemonnier,
Djibouti, is the only site we visited that has fully incorporated biometrics
screening into its contractor employee screening process. From April to
mid-December 2014 Camp Lemonnier, Djibouti, denied access to six
contractor personnel after finding derogatory information on them through
its biometric screening process.
Security officials at Camp Lemonnier, Djibouti, also use biometric and
document and media exploitation systems to upload contractor
employees’ biometrics and personal documentation to the larger DOD
intelligence enterprise (see figure 7). Uploading of personal
47
AFRICOM Biometric Concept of Operations, Aug. 2009.
Page 34
GAO-16-105 Operational Contract Support
documentation into U.S. intelligence databases refers to document and
media exploitation, which consists of the collection, analysis, and
exploitation of equipment, personal documents, and media to generate
actionable intelligence. This information can then be accessed by
intelligence officials if the contractor employee attempts to access another
DOD site. For example, from April to mid-December 2014 security
officials at Camp Lemonnier, Djibouti, placed 30 contractor employees on
a watch list based on their negative activity.
Figure 7: Camp Lemonnier, Djibouti, Contractor Employee Screening Process
Moreover, with the exception of Camp Lemonnier, Djibouti, contractor
employee screening processes are not well-documented in local base
security guidance. Joint Publication 4-10 states that commanders must
ensure that local screening and badging policies and procedures are in
Page 35
GAO-16-105 Operational Contract Support
place for all contractor personnel requiring access to U.S. facilities. 48 We
found that Camp Lemonnier, Djibouti, was the only site of the three we
visited that had clearly outlined contractor employee screening processes
in local base security guidance. The Air Force’s site in Niamey, Niger, has
base security guidance, but it does not describe its contractor employee
screening process.
One reason cited by officials for not developing local contractor employee
screening procedures and policies was that AFRICOM has not yet
specified what measures should be incorporated into the sites’ contractor
employee screening processes. DOD Instruction 2000.12, providing
guidance for the DOD Antiterrorism Program, states that combatant
commands shall establish antiterrorism policies and programs for the
protection of all DOD elements and personnel in their areas of
responsibility. 49 One of the minimum elements of an antiterrorism
program is risk management. Antiterrorism risk management includes the
determination of how best to employ given resources and force protection
measures to deter, mitigate, or prepare for a terrorist incident. 50 Those
measures could include contractor employee screening measures.
AFRICOM drafted contractor employee screening guidance in November
2014, which it subsequently updated. As of June 2015, AFRICOM
officials stated that the guidance was under review, but they did not
provide a timeframe for its issuance. This draft guidance would provide
that screening measures, including biometric screening, should be in
place when non-U.S. personnel have access to AFRICOM-controlled
facilities. The draft guidance contains a detailed appendix that describes
under what conditions biometric screening should be conducted, and it
discusses document and media exploitation. However, it lacks additional
information regarding when other screening measures should be
implemented. Officials at the sites we visited stated that access to
biometric collection equipment and counterintelligence agents constituted
a challenge due to limited resources. As a result, although AFRICOM’s
draft guidance would direct sites to perform additional screening
measures whenever a non-U.S. contractor employee requires access to
48
Joint Pub. 4-10, at V-25 (July 16, 2014).
49
Department of Defense Instruction 2000.12, DOD Antiterrorism (AT) Program, encl. 2,
para. 20.b (Mar. 1, 2012) (incorporating change Sept. 9, 2013).
50
See id. at 29; see also Department of Defense Instruction 2000.16, DoD Antiterrorism
(AT) Standards, encl. 3, para. E3.3 (Oct. 2, 2006) (incorporating change, Dec. 8, 2006).
Page 36
GAO-16-105 Operational Contract Support
them, the sites may not have the resources to implement the guidance,
when issued.
Furthermore, risk varies from site to site, depending on a number of
factors, such as the location’s threat profile, operations, and numbers and
types of personnel. Risk-based guidance that indicates the specific
measures to be incorporated into contractor employee screening
processes could better position AFRICOM components to conduct the
appropriate level of screening and effectively allocate screening
resources to protect DOD personnel and facilities from insider threats.
Conclusions
DOD has spent billions of dollars on contract support since 2002, and as
its footprint in Africa increases it is more frequently relying on contractor
support for a range of operations to provide logistical, transportation, and
intelligence support to AFRICOM’s missions. The enhanced capabilities
offered by OCS can be a significant force multiplier in every phase of joint
and coalition operations in Africa. Conversely, the inability to effectively
manage and plan for OCS could yield unintended consequences such as
higher costs and inadvertent contracting with vendors that have ties to
violent extremist organizations that could complicate or even undermine
operational objectives. While AFRICOM has taken steps to manage and
plan for OCS, challenges remain in areas such as development of OCS
structures, assessments of subordinate command capabilities, accounting
of the total number of contractor personnel, and contractor vetting.
Several of AFRICOM’s subordinate commands—service component and
joint force commands—lack organizational structures, such as OCS
Integration Cells, with dedicated personnel to manage and plan for OCS.
A structure such as an OCS Integration Cell would be particularly useful
in a joint environment, such as Combined Joint Task Force-Horn of
Africa, due to the number of military service contracting elements
operating at the same location, with potentially limited resources.
Additionally, clearly defined assessment standards could help AFRICOM
to more accurately assess the OCS actions taken by subordinate
commands. Furthermore, AFRICOM cannot comprehensively account for
DOD contractors on the continent because AFRICOM and joint staff
guidance is unclear regarding the types of contractors who should be
accounted for and by which personnel accountability process. Clear
guidance could help AFRICOM to determine how many contractors
support DOD operations in the region, providing commanders with
greater visibility over who is supporting DOD operations in the area of
responsibility. Also, AFRICOM has not established a foreign vendor
vetting process to preemptively identify vendors that support criminal,
Page 37
GAO-16-105 Operational Contract Support
terrorist, or other sanctioned organizations, because there is no DOD
guidance specifying conditions under which combatant commands should
have a vendor vetting process or cell in place to determine whether
potential vendors actively support any terrorist, criminal, or other
sanctioned organizations. Moreover, there is no guidance clarifying when
combatant commands should develop procedures for transmitting names
of vendors identified through such a vendor vetting process for inclusion
in prohibited entities lists. Finally, not all of the AFRICOM forward
operating sites we visited are incorporating additional screening
measures according to the specific risks at each site. The development of
a foreign vendor vetting process and risk-based employee screening
measures could help AFRICOM to determine appropriate levels for
vendor vetting and contractor employee screening on the African
continent.
Recommendations for
Executive Action
We recommend the following seven actions.
To enable AFRICOM’s component commands to better plan, advise, and
coordinate for OCS, we recommend that the AFRICOM Commander, as
part of AFRICOM’s ongoing efforts to update related guidance and
emphasize the importance of OCS integration at the subordinate
command level, take the following actions:
•
•
Direct the service components to designate elements within their
respective staffs to be responsible for coordinating OCS, and consider
the establishment of an OCS Integration Cell or similar structure with
these dedicated OCS personnel, as needed.
Clarify under what conditions a subordinate joint force command,
such as Combined Joint Task Force-Horn of Africa, should establish
an OCS Integration Cell.
To enable AFRICOM to better identify, address, and mitigate OCS
readiness gaps at its component commands before inaccurate
information is incorporated into formal defense readiness reporting
systems, we recommend that the AFRICOM Commander take the
following action:
•
Clarify the scorecard process, including assessment standards, for
OCS Readiness Scorecards to ensure that evaluators can accurately
assess subordinate commands’ OCS capabilities.
To enable AFRICOM to comprehensively and consistently account for
contractor personnel in Africa, we recommend that:
Page 38
GAO-16-105 Operational Contract Support
•
•
The Secretary of Defense, in coordination with the Chairman of the
Joint Chiefs of Staff, direct Joint Staff to clarify what types of
contractor personnel should be accounted for in its guidance on
personnel status reports.
The AFRICOM Commander develop area of responsibility-wide
contractor personnel accountability guidance on or before December
2015, when the current guidance expires, that clarifies which types of
contractor personnel should be accounted for using SPOT, and when
SPOT accountability requirements should be incorporated into
contracts.
To ensure that combatant commands are not contracting with entities that
may be connected to or supporting prohibited organizations, we
recommend that the Secretary of Defense, in coordination with the
Chairman of the Joint Chiefs of Staff, take the following action:
•
Develop guidance that clarifies the conditions under which combatant
commands should have a foreign vendor vetting process or cell in
place to determine whether potential vendors actively support any
terrorist, criminal, or other sanctioned organizations, including
clarifying when combatant commands should develop procedures for
transmitting the names of any vendors identified through this process
for inclusion in prohibited entities lists in the appropriate federal
contracting databases, such as the System for Award Management.
To ensure that AFRICOM applies a risk-based approach to contractor
employee screening in Africa, we recommend that the Secretary of
Defense take the following action:
•
Agency Comments
and Our Evaluation
Direct AFRICOM to complete and issue guidance that specifies the
standard of contractor employee screening for forward operating sites,
based on factors such as the number of DOD personnel on base, type
of operations, and local security threat.
In written comments on a draft of this report, DOD concurred with four of
our recommendations, partially concurred with two, and did not concur
with our recommendation related to AFRICOM contractor personnel
accountability guidance. DOD’s comments are summarized below and
reprinted in appendix II. DOD also provided technical comments, which
we incorporated where appropriate.
DOD partially concurred with our first recommendation, that AFRICOM
direct its service components to designate elements within their
respective staffs to be responsible for coordinating OCS, and consider the
Page 39
GAO-16-105 Operational Contract Support
establishment of an OCS Integration Cell or similar structure with
dedicated OCS personnel. DOD stated that AFRICOM is assessing its
subordinate commands’ OCS structures to determine the best way
forward, and acknowledges that there are clear advantages and benefits
to establishing an OCS Integration Cell at the service-component level
even though there is no doctrinal requirement to do so. As we discuss in
the report, while joint staff guidance does not require the establishment of
an OCS Integration Cell or dedicated OCS personnel at the service
component command level, joint staff has emphasized the benefits of
using an OCS Integration Cell to synchronize requirements and
coordinate contracting actions. This recommendation was intended to
provide service component commands with the flexibility to develop OCS
Integration Cells or similar structures with dedicated OCS personnel who
can address these concerns. Moreover, an OCS Integration Cell or
similar structure could help identify contract support issues early in the
requirements development process, thereby enabling the service
component commands to avoid delays in receiving needed equipment or
services. Further, this designation would better ensure AFRICOM’s
component commands effectively plan, advise, and coordinate OCS
activities and meet the intent of the recommendation.
DOD concurred with our second recommendation, that AFRICOM clarify
under what conditions a subordinate joint force command, such as
Combined Joint Task Force-Horn of Africa, should establish an OCS
Integration Cell. In its comments, AFRICOM stated that all subordinate
joint force commands should establish an OCS Integration Cell.
AFRICOM further stated that it had scheduled a staff assistance visit to
Combined Joint Task Force-Horn of Africa to assess and develop a plan
for establishing an OCS Integration Cell. We acknowledge that
AFRICOM’s statement in its comments clarifies that an OCS Integration
Cell should be established at a subordinate joint force command, and
believe that the scheduling of a staff assistance visit to Combined Joint
Task Force-Horn of Africa is a positive first step toward establishing a cell
there. However, we also believe that providing that clarification in
AFRICOM guidance would better ensure the establishment of such a cell
at various types of subordinate joint force commands. As we noted in the
report, an OCS Integration Cell was established at AFRICOM’s
subordinate joint force command supporting Operation United Assistance
in 2014, but not at the Combined Joint Task Force-Horn of Africa in
Djibouti, or Special Operations Command Africa. Furthermore, AFRICOM
officials stated they conducted a staff assistance visit to Combined Joint
Task Force-Horn of Africa in August 2015 to assess and develop a plan
to establish an appropriate OCS structure there. Guidance clarifying
Page 40
GAO-16-105 Operational Contract Support
under what conditions a subordinate joint force command should
establish an OCS Cell, if fully implemented, would meet the intent of our
recommendation.
DOD partially concurred with the third recommendation, that AFRICOM
clarify the scorecard process, including assessment standards, for OCS
Readiness Scorecards to ensure that evaluators can accurately assess
subordinate commands’ OCS capabilities. DOD stated that the scorecard
is a command initiative designed to drive discussion about OCS issues
with subordinate commands, but is not a replacement for the Defense
Readiness Reporting System to report OCS. We agree that the scorecard
is not such a replacement. However, as noted in the report, AFRICOM
officials stated that they plan to incorporate OCS scorecards into the
Defense Readiness Reporting System, the system used to gauge
readiness across DOD. This recommendation was intended to ensure
that OCS scorecard assessment standards are clearly defined so that
AFRICOM can accurately assess OCS actions taken by subordinate
commands. Without improvements, either full or partial incorporation of
the scorecard assessments into DOD’s readiness reporting system could
compromise the integrity of that system by capturing an inaccurate picture
of OCS readiness.
DOD concurred with our fourth recommendation, that the Secretary of
Defense, in coordination with the Chairman of the Joint Chiefs of Staff,
direct Joint Staff to clarify what types of contractor personnel should be
accounted for in its guidance on personnel status reports. In its
comments, DOD stated that Chairman of the Joint Chiefs of Staff Manual
3150.13C, Joint Personnel Reporting Structure-Personnel Manual
provides policy and guidance on what types of contractor personnel to
account for in personnel status reports, but that additional training and
amplifying local procedures issued by AFRICOM’s personnel directorate
may be needed to fully implement its provisions and ensure consistent
interpretation of the guidance. As we noted in the report, the Chairman of
the Joint Chiefs of Staff guidance identifies SPOT as the designated webbased contractor database and lists the types of contractor personnel
included in SPOT—including U.S., local national, host nation, and third
country national—but it does not clearly specify the types of contractor
personnel to report in the daily personnel status report, and as a result,
service component officials at some forward operating sites inconsistently
included various types of contractors in personnel status reports. While
we believe that additional guidance provided by AFRICOM’s personnel
directorate would provide further clarification on this issue, we continue to
believe that clarifying Joint Staff guidance to clearly specify the types of
Page 41
GAO-16-105 Operational Contract Support
contractor personnel to be accounted for in joint personnel status reports
would provide AFRICOM better assurance that its staff consistently
provides it with comprehensive information.
DOD did not concur with the fifth recommendation, that the Secretary of
Defense, in coordination with the Chairman of the Joint Chiefs of Staff,
direct AFRICOM to develop area of responsibility-wide contractor
personnel accountability guidance on or before December 2015, when
the current guidance expires, that clarifies which types of contractor
personnel should be accounted for using SPOT and when SPOT
accountability requirements should be incorporated into contracts. DOD
stated that there is not a requirement for the Secretary of Defense to
direct AFRICOM to develop this guidance. We agree that it may not be
necessary for the Secretary of Defense to direct this action and
accordingly adjusted the language of the recommendation directly to
AFRICOM. Additionally, DOD stated it is coordinating a draft class
deviation to the Defense Federal Acquisition Regulation Supplement on
accountability requirements for contractor personnel performing in the
AFRICOM area of responsibility, which it expects to be approved and
published by December 2015. We acknowledge that this class deviation,
when completed, may provide further clarity on the types of contractor
personnel to include in SPOT. However, we continue to believe that
AFRICOM could benefit from developing and issuing contractor personnel
accountability guidance for its area of responsibility. Specifically, as we
noted in the report, there have been no changes to the Defense Federal
Acquisition Regulation Supplement to date on this topic, DOD has not
issued a Class Deviation, and AFRICOM’s existing interim guidance
expires in December 2015. Thus, we continue to believe that clear
accountability guidance would enable AFRICOM to more consistently and
comprehensively determine how many contractor personnel support DOD
operations in the region.
DOD concurred with our sixth recommendation, that the Secretary of
Defense, in coordination with the Chairman of the Joint Chiefs of Staff,
develop guidance that clarifies the conditions under which combatant
commands should have a foreign vendor vetting process or cell in place
to determine whether potential vendors actively support any terrorist,
criminal or other sanctioned organizations, including clarifying when
combatant commands should develop procedures for transmitting the
names of any vendors identified through this process for inclusion in
prohibited entities list in the appropriate federal contracting databases,
such as the System for Award Management. In its comments, DOD
stated that OSD has established a joint working group to identify key
Page 42
GAO-16-105 Operational Contract Support
stakeholders and develop DOD policy requiring combatant commands to
develop foreign vendor vetting processes. When fully implemented, we
believe these actions would meet the intent of our recommendation.
DOD concurred with our seventh recommendation, that AFRICOM
continue to complete and issue guidance that specifics the standard of
contractor employee screening for forward operating sites, based on
factors such as the number of DOD personnel on base, type of
operations, and local security threat. In its comments, DOD stated that
AFRICOM has completed the staffing of a draft instruction that will
provide guidance and specify the standards for contractor employee
screening for forward operating sites, including a risk-based approach to
contractor employee screening based on applicable mitigating factors that
include the type of contractor, operations and local security threat. While
we have not seen an updated version of this draft guidance that includes
a risk-based approach to screening, if it is fully implemented as described
above, it would meet the intent of our recommendation.
We are providing copies of this report to the appropriate congressional
committees, the Secretary of Defense, the Chairman of the Joint Chiefs of
Staff and the AFRICOM Commander. In addition, this report is available
at no charge on the GAO website at http://www.gao.gov.
If you or your staff have any questions about this report, please contact
me at (202) 512-5431 or russellc@gao.gov. Contact points for our Offices
of Congressional Relations and Public Affairs may be found on the last
page of this report. GAO staff who made key contributions to this report
are listed in appendix III.
Cary B. Russell
Director, Defense Capabilities and Management
Page 43
GAO-16-105 Operational Contract Support
Appendix I: Objectives, Scope, and
Methodology
Appendix I: Objectives, Scope, and
Methodology
The objectives of our review were to determine the extent to which
AFRICOM: (1) has an organizational structure in place to manage, plan
for, and assess operational contract support; (2) accounts for contractor
personnel in its area of responsibility; and (3) vets non-U.S. contractors
and contractor employees. The focus of this review was on AFRICOM
and its subordinate commands, including the service component
commands, as well as Special Operations Command Africa in Europe,
and the Combined Joint Task Force-Horn of Africa at Camp Lemonnier in
Djibouti. Further, in terms of our review of AFRICOM contractor personnel
accountability and contractor vetting, our scope included only contract
support on the African continent, excluding contract support located at
AFRICOM headquarters.
To determine the extent to which AFRICOM has an organizational
structure in place to manage, plan for, and assess operational contract
support, we gathered information from and conducted interviews with
officials at AFRICOM headquarters, as well as the AFRICOM service
component command headquarters in Europe. To determine the extent to
which AFRICOM assesses OCS capabilities, we evaluated the OCS
readiness scorecards created by AFRICOM J4 (Logistics Directorate) to
measure its service components’ OCS capabilities in 2014. In its
assessment of the component commands, AFRICOM J4 rated each
service component as compliant, partially compliant, or non-compliant
with OCS tasks for four performance measure categories: planning,
policy, operations/exercises/security cooperation, and administration. We
evaluated the ratings that J4 applied to the service components in these
categories to determine whether they were accurate. Specifically, to
evaluate the accuracy of the scorecard ratings, we validated the ratings
using evidence gathered from the service components and compared
ratings of the service components with similar conditions against one
another to determine whether they received the same ratings. To
evaluate the extent to which AFRICOM plans for OCS, we reviewed OCS
annexes—Annex W’s—to AFRICOM’s theater campaign plan and its
regional campaign plans to determine the extent to which they included
key OCS concepts outlined in DOD and joint staff guidance.
To determine the extent to which AFRICOM accounts for contractor
personnel, we reviewed DOD, AFRICOM, and Joint Staff personnel
accountability guidance and interviewed AFRICOM J1 officials, as well as
military service officials with personnel accountability responsibilities at
the AFRICOM forward operating sites we visited. In addition, we reviewed
contracts with place of performance in Djibouti from March 2013 to
February 2014, as well as Operation United Assistance (OUA) contracts
Page 44
GAO-16-105 Operational Contract Support
Appendix I: Objectives, Scope, and
Methodology
from December 2014 to February 2015 listed in the All Government
Contract Spend data, to determine whether they included clauses to
register employees supporting the contracts in the Synchronized
Predeployment and Operational Tracker (SPOT). The different
timeframes used for the selection of those contracts were based, in part,
on the timing of various DOD requirements to use clauses that included
SPOT-related provisions. Finally, we reviewed monthly SPOT data from
2011 to 2015 provided by AFRICOM personnel officials to determine
whether the numbers of contractor personnel had increased or decreased
within the past 5 years. We conducted a data reliability analysis of this
information, including corroborating the data with agency officials to
ensure that it is accurate, up-to-date and reasonable. We determined the
data to be sufficient and reliable for the purposes of this report.
To determine the extent to which AFRICOM vets contractors and
contractor employees we reviewed DOD and military department
contracting, anti-terrorism, and physical security guidance and compared
it to information gathered from AFRICOM J2X (counterintelligence) and
three forward operating sites concerning their vendor vetting and
contractor employee screening processes. In addition, we observed
contractor screening and base access procedures at the forward
operating sites in Djibouti, Niger, and Uganda. We selected these
locations based on variations in the military services represented, the
types of contractors (U.S., third country, and local national), and the types
of contract services provided. The information gathered from these three
sites, while not generalizable to all AFRICOM sites, provides valuable
insights about personnel accountability, contractor vetting, and contractor
employee screening processes in the AFRICOM area of responsibility.
We visited or contacted officials from the following DOD organizations
during our review:
Department of Defense
•
•
•
•
•
•
•
•
Office of the Under Secretary of Defense for Acquisition, Technology
and Logistics
Defense Procurement and Acquisition Policy Directorate
Office of the Under Secretary of Defense for Personnel and
Readiness
Office of the Under Secretary of Defense for Intelligence
Chairman of the Joint Chiefs of Staff
Joint Staff J-4 (Logistics) Directorate
AFRICOM Headquarters, Stuttgart, Germany
AFRICOM J-1 (Personnel) Directorate, Stuttgart, Germany
Page 45
GAO-16-105 Operational Contract Support
Appendix I: Objectives, Scope, and
Methodology
Department of the Air
Force
Department of the Army
Department of the Navy
•
•
•
•
•
•
•
•
•
•
•
•
•
AFRICOM J-2 (Intelligence) Directorate, Stuttgart, Germany
AFRICOM J-3 (Operations) Directorate, Stuttgart, Germany
AFRICOM J-4 (Logistics) Directorate, Stuttgart, Germany
Special Operations Command Africa, Stuttgart, Germany
Special Operations Forward – Eastern Area, Uganda
Special Operations Forward – Central Area, Uganda
Combined Joint Task Force-Horn of Africa
J-1 (Personnel) Directorate, Camp Lemonnier, Djibouti
J-2 (Intelligence) Directorate, Camp Lemonnier, Djibouti
J-3 (Operations) Directorate, Camp Lemonnier, Djibouti
J-4 (Logistics) Directorate, Camp Lemonnier, Djibouti
J-5 (Plans) Directorate, Camp Lemonnier, Djibouti
Contingency Contracting Office, Camp Lemonnier, Djibouti
•
•
•
•
•
•
U.S. Air Forces in Europe–Air Forces Africa, Ramstein, Germany
U.S. Air Force 449th Air Expeditionary Group, Camp Lemonnier,
Djibouti
768th Air Expeditionary Squadron at Niamey, Niger
Contracting Office, Niamey, Niger
Security Forces and Office of Special Investigations, Niamey, Niger
Air Force A-1 (Personnel), Niamey, Niger
•
•
•
•
•
•
•
Office of the Deputy Chief of Staff, G-4 (Logistics), Washington, D.C.
U.S. Army Africa, Vicenza, Italy
G-1 (Personnel) Directorate, Vicenza, Italy
G-2 (Intelligence) Directorate, Vicenza, Italy
G-4 (Logistics) Directorate, Vicenza, Italy
414th Contract Support Brigade, Vicenza, Italy
Air Force Office of Special Investigations, Niamey, Niger
•
Deputy Assistant Secretary of the Navy – Acquisition and
Procurement, Washington, D.C.
U.S. Naval Forces Europe–Africa, Naples, Italy
Naval Forces Africa N-4 (Logistics) Directorate, Naples, Italy
Naval Forces Africa N-1 (Personnel) Directorate, Naples, Italy
Naval Facilities Command Europe, Africa, Southwest Asia, Naples,
Italy
Naval Supply Systems Command, Fleet Logistics Center Sigonella,
Naples, Italy
U.S. Marine Corps Forces Europe and Africa, Stuttgart, Germany
Special Purpose Marine Air Ground-Task Force, Uganda
U.S Naval Camp Lemonnier, Djibouti
•
•
•
•
•
•
•
•
Page 46
GAO-16-105 Operational Contract Support
Appendix I: Objectives, Scope, and
Methodology
Department of State
•
•
•
•
N-1 (Personnel), Camp Lemonnier, Djibouti
Public Works Office/Contracting Office, Camp Lemonnier, Djibouti
Base Access Control Office, Camp Lemonnier, Djibouti
Naval Criminal Investigative Services, Camp Lemonnier, Djibouti
•
•
•
•
•
•
•
Office of Acquisitions Management, Washington, D.C.
Office of Logistics Management, Washington, D.C.
Bureau of African Affairs, Washington, D.C.
Bureau of Diplomatic Security, Washington, D.C.
U.S. Embassy, Djibouti, Djibouti
U.S. Embassy, Niamey, Niger
U.S. Embassy, Kampala, Uganda
We conducted this performance audit from June 2014 to December 2015
in accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our audit objectives. We believe that
the evidence obtained provides a reasonable basis for our findings and
conclusions based on our audit objectives.
Page 47
GAO-16-105 Operational Contract Support
Appendix II: Comments from the Department
of Defense
Appendix II: Comments from the Department
of Defense
GAO sent a draft of this
report to DOD for
comment on July 2,
2015, identified as
GAO-15-679. GAO
received DOD’s
comments on
November 20, 2015.
The report number was
changed to GAO-16105 to reflect the
appropriate fiscal year
of issuance.
Page 48
GAO-16-105 Operational Contract Support
Appendix II: Comments from the Department
of Defense
Page 49
GAO-16-105 Operational Contract Support
Appendix II: Comments from the Department
of Defense
Page 50
GAO-16-105 Operational Contract Support
Appendix II: Comments from the Department
of Defense
Page 51
GAO-16-105 Operational Contract Support
Appendix III: GAO Contact and Staff
Acknowledgments
Appendix III: GAO Contact and Staff
Acknowledgments
GAO Contact
Cary Russell, (202) 512-5431 or russellc@gao.gov
Staff
Acknowledgments
In addition to the contact named above, Carole Coffey and James A.
Reynolds, Assistant Directors; Gregory Hellman; Courtney Reid; Michael
Shaughnessy; Michael Silver; Amie Steele; Cheryl Weissman; and
Amanda Weldon made key contributions to this report.
Page 52
GAO-16-105 Operational Contract Support
Related GAO Products
Operational Contract Support: Actions Needed to Enhance the Collection,
Integration, and Sharing of Lessons Learned. GAO-15-243. Washington,
D.C.: March 16, 2015.
Contingency Contracting: Contractor Personnel Tracking System Needs
Better Plans and Guidance. GAO-15-250. Washington, D.C.: February
18, 2015.
High Risk Series: An Update. GAO-15-290. Washington, D.C.: February
11, 2015.
Defense Acquisitions: Update on DOD’s Efforts to Implement a Common
Contractor Manpower Data System. GAO-14-491R.Washington, D.C.:
May 19, 2014.
Warfighter Support: DOD Needs Additional Steps to Fully Integrate
Operational Contract Support into Contingency Planning.
GAO-13-212.Washington, D.C.: February 8, 2013.
Operational Contract Support: Management and Oversight Improvements
Needed in Afghanistan. GAO-12-290. Washington, D.C.: March 29, 2012.
Afghanistan: U.S. Efforts to Vet Non-U.S. Vendors Need Improvement.
GAO-11-355. Washington, D.C.: June 8, 2011.
Warfighter Support: Cultural Change Needed to Improve How DOD Plans
for and Manages Operational Contract Support. GAO-10-829T.
Washington, D.C.: June 29, 2010.
Warfighter Support: DOD Needs to Improve Its Planning for Using
Contractors to Support Future Military Operations.
GAO-10-472.Washington, D.C.: March 30, 2010.
Contingency Contract Management: DOD Needs to Develop and Finalize
Background Screening and Other Standards for Private Security
Contractors. GAO-09-351. Washington, D.C.: July 31, 2009.
Military Operations: DOD Needs to Address Contract Oversight and
Quality Assurance Issues for Contracts Used to Support Contingency
Operations. GAO-08-1087. Washington, D.C.: September 26, 2008.
Military Operations: Background Screenings of Contractor Employees
Supporting Deployed Forces May Lack Critical Information, but U.S.
Page 53
GAO-16-105 Operational Contract Support
Forces Take Steps to Mitigate the Risk Contractors May Pose.
GAO-06-999R. Washington, D.C.: September 22, 2006.
(351933)
Page 54
GAO-16-105 Operational Contract Support
GAO’s Mission
The Government Accountability Office, the audit, evaluation, and
investigative arm of Congress, exists to support Congress in meeting its
constitutional responsibilities and to help improve the performance and
accountability of the federal government for the American people. GAO
examines the use of public funds; evaluates federal programs and
policies; and provides analyses, recommendations, and other assistance
to help Congress make informed oversight, policy, and funding decisions.
GAO’s commitment to good government is reflected in its core values of
accountability, integrity, and reliability.
Obtaining Copies of
GAO Reports and
Testimony
The fastest and easiest way to obtain copies of GAO documents at no
cost is through GAO’s website (http://www.gao.gov). Each weekday
afternoon, GAO posts on its website newly released reports, testimony,
and correspondence. To have GAO e-mail you a list of newly posted
products, go to http://www.gao.gov and select “E-mail Updates.”
Order by Phone
The price of each GAO publication reflects GAO’s actual cost of
production and distribution and depends on the number of pages in the
publication and whether the publication is printed in color or black and
white. Pricing and ordering information is posted on GAO’s website,
http://www.gao.gov/ordering.htm.
Place orders by calling (202) 512-6000, toll free (866) 801-7077, or
TDD (202) 512-2537.
Orders may be paid for using American Express, Discover Card,
MasterCard, Visa, check, or money order. Call for additional information.
Connect with GAO
Connect with GAO on Facebook, Flickr, Twitter, and YouTube.
Subscribe to our RSS Feeds or E-mail Updates.
Listen to our Podcasts and read The Watchblog.
Visit GAO on the web at www.gao.gov.
To Report Fraud,
Waste, and Abuse in
Federal Programs
Contact:
Website: http://www.gao.gov/fraudnet/fraudnet.htm
E-mail: fraudnet@gao.gov
Automated answering system: (800) 424-5454 or (202) 512-7470
Congressional
Relations
Katherine Siggerud, Managing Director, siggerudk@gao.gov, (202) 5124400, U.S. Government Accountability Office, 441 G Street NW, Room
7125, Washington, DC 20548
Public Affairs
Chuck Young, Managing Director, youngc1@gao.gov, (202) 512-4800
U.S. Government Accountability Office, 441 G Street NW, Room 7149
Washington, DC 20548
Please Print on Recycled Paper.